Valid when made

Under this doctrine, debt buyers may purchase loans from national banks and collect interest at the same rate as the original lender, regardless of the usury laws of the state they operate in.

[6] After the ruling, courts generally held that debt buyers could collect interest at the originally set rate, despite not being subject to the same protections as national banks.

[8] This dynamic became a major component of the "rate exportation model" of lending, under which national banks sold or transferred loans.

[13][14] The ruling also prompted concerns that loans that had previously been legally valid might become usurious, opening up secondary lenders to civil and criminal charges.

[16] Multiple bills were proposed to implement such a law, including the Protecting Consumers’ Access to Credit Act 2017, which was passed by the U.S. House Of Representatives.

[1] The Federal Deposit Insurance Corporation (FDIC) also reaffirmed and codified valid-when-made doctrine, arguing that Madden was a "deviation from longstanding notions of contract law" and had created market instability.